William Hill condemned by UK ASA for accidentally advertising to children

William Hill condemned by UK ASA for accidentally advertising to children

Thursday, September 20, 2018 Posted by News Team
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Operator warned to use in-depth campaign targeting to avoid repeat offences

UK ad watchdog the Advertising Standards Authority (ASA) has warned William Hill over its future conduct after a promotion for its William Hill Vegas casino appeared on an app that may be popular among minors. 

The offending ad appeared within the New MarioKart 8 Trick app, and included text which stated: “William Hill Vegas ... All Online Vegas Games 200% Up To £200 Bonus William Hill Vegas”. It was accompanied by a button which players could click to install the Vegas app.

This prompted a complaint from an individual, who queried whether the ad was appropriately targeted, as it was featured in an app for a console game popular among children. MarioKart 8, which was released for the Nintendo Switch in 2014, has been given a rating of 3 by the PEGI content rating system, denoting it as appropriate for those aged 3 and above. 

In response, William Hill said it would never knowingly target children or those aged under 18. The operator said it had used Google’s Universal App Campaign product, which rolled out its ads across Search, Google Display Network, YouTube and the Google Play Store, meaning there was little it could do to specify where its ads should appear. 

William Hill went on to say that the ads were limited to appear for those that had specified they were aged 18 or above. As the device on which the ad had been had been used either for betting-related or adult-themed content, this suggested the user or device owner was over 18. The ad could have also appeared as a result of cross-device advertising, where a user that had a desktop William Hill account logged in via their mobile or tablet device. 

The operator went on to point out that when devices were shared between adults and minors, there was no way it could entirely exclude children from seeing gambling ads in this case. In the case of the ad on the MarioKart app, it had appeared as a consequence of retargeting a campaign that was based on previous browsing habits and cookies - something that was widely used by a number of commerce businesses.

To avoid a similar situation in future, William Hill said it was working with childrens’ publishers, and that it hoped that none of its content would be made available on devices where child-related content had been accessed. 

It also noted that Nintendo had reported that 86% of its Switch console players were aged more than 18, and that Mario Kart was one of the most popular games on its platform. This, it said, suggested that Mario Kart was predominantly played by older individuals. 

While the app developer Honocoroko did not respond to the ASA’s enquiries, Google provided evidence to the authority. It said that gambling ads were served by its AdMob ad network, and served to signed-in users aged 18 or over. 

However, it noted that the Universal App Campaign feature gave advertisers tools to ensure their ads would not appear in certain places, including exclusions of certain categories of mobile apps, exclusions content suitable for different types of audiences and exclusions of certain types of content. 

Google also noted that William Hill’s claims that it had used digital footprints and retargeting campaigns based on previous browsing habits and cookies. This, Google said, were not permitted for gambling advertisers, and that such retargeting was not an option available through the Universal App Campaign feature. 

The ASA therefore upheld the complaint, ruling that William Hill was in breach of CAP Code rule 16.3.13, banning gambling marketing communications from being targeted at minors. 

The ASA said that marketers should be able to demonstrate that gambling advertisers had taken reasonable steps to ensure their ads were targeted at an appropriate audience. However, it acknowledged that it was difficult to prevent minors from seeing some gambling ads, as young people often misreported their age online, and certain products would be of appeal to a wide range of different ages. 

Despite this, it said that the Google AdWords tools, including Universal App Campaign, allowed advertisers to target groups based on interest, allowing them to ensure their products were not likely to be seen by minors. As Mario Kart would have been of appeal to those aged over and under 18, William Hill should have used additional interest-based factors to reduce the likelihood of under-18s from seeing the app, the ASA explained. 

It went on to say that Universal App Campaign did allow advertisers to apply account extensions to prevent their ads from appearing in particular types of ads and websites, including sites suitable for a wider range of audiences. However, William Hill did not use these tools. It also failed to use Google AdWords tools allowing it to target campaigns based on interest and other behavioural factors. 

The ASA therefore concluded that the ad had breached the Cap Code. It warned William Hill to use more in-depth targeting for ad campaigns in future to minimise the likelihood of under-18s seeing it ads.

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